New Compliance Requirements for Digital Record-Keeping and Making Tax Digital (MTD)
The UK government’s Making Tax Digital (MTD) initiative aims to streamline tax processes and improve record-keeping accuracy through digital solutions. MTD has been gradually rolled out since 2019, starting with VAT, and now, HMRC is extending it to more taxpayers and introducing additional compliance requirements for digital record-keeping.
Let’s explore the latest MTD requirements, who they apply to, and how businesses and individuals can stay compliant.
1. Overview of Making Tax Digital (MTD)
Making Tax Digital (MTD) is a government initiative requiring businesses and individuals to use compatible digital software for tax record-keeping and reporting. The goal is to reduce errors, improve transparency, and allow HMRC more timely access to accurate financial information.
Key Elements of MTD:
- Digital Record-Keeping: Taxpayers must keep digital records of their transactions using compatible software.
- Quarterly Updates: Instead of annual tax returns, MTD requires quarterly updates to HMRC, providing more frequent insights into business performance.
- Digital Links: A clear digital audit trail is required between records and tax submissions, ensuring traceability and reducing manual adjustments.
2. Current and Upcoming MTD Compliance Requirements
A. MTD for VAT (Already in Effect)
MTD for VAT is mandatory for all VAT-registered businesses, regardless of turnover. Initially, only businesses with a turnover above the VAT threshold of £85,000 were required to comply, but this has since expanded to all VAT-registered businesses.
Requirements:
- Maintain digital records of VAT transactions.
- Use MTD-compatible software to submit VAT returns to HMRC.
- Keep a digital audit trail, linking records to VAT return submissions.
B. MTD for Income Tax Self Assessment (MTD for ITSA) – Effective April 2026
MTD for Income Tax Self Assessment (ITSA) is the next major step in the MTD rollout and is targeted at sole traders and landlords with gross income above £50,000. Originally set for April 2024, this has been deferred to allow taxpayers more time to prepare.
Requirements:
- Digital Record-Keeping: Maintain digital records for all business income and expenses using compatible software.
- Quarterly Updates: Submit income and expense updates to HMRC every quarter.
- End-of-Period Statement (EOPS): At the end of each tax year, submit a final EOPS to confirm income and expenses.
- Final Declaration: Replace the traditional Self Assessment return with a final declaration that consolidates all updates and adjustments.
Who’s Affected in 2026:
- Self-employed individuals and landlords with annual gross income above £50,000.
Further Rollouts:
- April 2027: MTD for ITSA will extend to self-employed individuals and landlords with gross income above £30,000.
C. Potential Expansion to Corporation Tax (Under Consultation)
HMRC is exploring the possibility of extending MTD to corporation tax for limited companies. Though no formal dates have been set, a pilot phase is expected in the coming years. This expansion could require companies to maintain digital records and submit quarterly updates for corporation tax purposes, similar to MTD for VAT and ITSA.
3. Digital Record-Keeping Compliance under MTD
To meet MTD requirements, businesses must adopt digital record-keeping practices that align with HMRC’s standards.
Key Requirements for Digital Record-Keeping:
- Use of MTD-Compatible Software: All records must be kept in MTD-compatible software that can link directly to HMRC’s systems. This software should be capable of:
- Recording transactions in real-time or near real-time.
- Generating reports and summaries needed for quarterly updates.
- Submitting returns directly to HMRC.
- Digital Links and Data Flow: MTD requires a clear digital link between records and submissions. This means that manual entry or “copy-pasting” between systems is not allowed after the data is initially recorded digitally.
- Examples of Digital Links: Importing data from spreadsheets into MTD-compatible software or using API links between accounting software and HMRC’s system.
- Detailed Record of Each Transaction: Businesses must keep a record of every transaction with the following details:
- For Sales: Date, total amount, VAT charged, and invoice number.
- For Purchases: Date, supplier information, VAT amount, and description of the expense.
- End-of-Period Statements: For income tax, taxpayers will need to reconcile and submit an end-of-period statement (EOPS) to confirm the accuracy of quarterly submissions.
4. Software Requirements and Choosing MTD-Compatible Solutions
HMRC provides a list of MTD-compatible software that meets its requirements. Businesses and individuals should select software that best aligns with their needs while ensuring it’s compatible with HMRC’s systems.
Tips for Selecting MTD-Compatible Software:
- Check HMRC’s Approved List: HMRC’s website maintains an up-to-date list of approved software providers.
- Consider Key Features: Look for software that can handle digital links, has robust reporting features, and integrates with other business tools.
- Evaluate Costs: MTD-compatible software ranges from free versions for smaller businesses to more comprehensive solutions for larger companies, so consider costs relative to your business size.
- Look for MTD ITSA Compatibility: For self-employed individuals and landlords preparing for MTD for ITSA, ensure your software is ready for income tax reporting requirements.
5. Penalties for Non-Compliance with MTD
With MTD, HMRC has introduced a new points-based penalty system for non-compliance. Each missed submission or late payment accrues points, which can result in penalties if the threshold is reached.
Points-Based Penalty System:
- Late Filing: Points are accrued for each late filing, with penalties issued upon reaching a threshold.
- VAT returns: 4 points threshold before penalties apply.
- Quarterly income tax updates: Thresholds vary based on the number of required submissions.
- Late Payment: Penalties will be charged on overdue payments, starting at 2% for payments more than 15 days late, increasing after 30 days.
Penalty Waivers and Points Reset:
- Points can be reset after a period of compliance, so consistent on-time submissions will eventually eliminate accrued points.
6. Preparing for MTD Compliance
Adapting to MTD requirements involves several steps, from upgrading your accounting software to training staff on new digital processes.
Steps to Prepare for MTD:
- Review Current Record-Keeping Practices: Assess your current record-keeping and VAT submission processes. Identify areas where you can streamline or digitize data entry to align with MTD requirements.
- Upgrade to MTD-Compatible Software: If you’re not already using compatible software, upgrade or migrate your data to an MTD-approved solution that suits your business.
- Train Staff: Ensure that your finance team or anyone involved in record-keeping is trained on digital processes, quarterly submissions, and maintaining digital links.
- Establish a Digital Link Process: Set up digital links between different systems or software to minimize manual input, reduce errors, and ensure compliance with HMRC’s audit trail requirements.
- Monitor Quarterly Submission Deadlines: Familiarize yourself with MTD quarterly deadlines and set reminders for submissions and updates to avoid penalties.
7. Seek Professional Advice for MTD Transition
Transitioning to MTD, especially for larger or more complex businesses, may require professional guidance to ensure compliance.
- VAT Specialists and Accountants: Professionals familiar with MTD can provide insights into best practices, recommend software, and assist with setting up digital record-keeping and linking processes.
- Training Programs: Many accounting firms offer training sessions specifically tailored to MTD compliance, covering everything from software selection to maintaining digital links.
Key Takeaways
Making Tax Digital is transforming the way businesses and individuals manage their tax affairs. By ensuring digital record-keeping, meeting quarterly update requirements, and maintaining a digital link for all transactions, you can stay compliant and benefit from streamlined tax reporting.
Summary of Actions for MTD Compliance:
- Use MTD-compatible software and ensure it can handle digital links.
- Prepare for quarterly updates for VAT and (soon) income tax submissions.
- Stay informed about penalties and avoid late submissions or payments.
- Seek advice or training if your business needs support transitioning to digital record-keeping.
With MTD set to cover more taxpayers in the coming years, early preparation will make compliance easier and help you leverage the benefits of a digital tax system.



